https://www.taxtmi.com/caselaws?id=759032 Gujarat HC held that reassessment notice u/s 148 was invalid as it constituted mere change of opinion. Revenue authorities lacked new tangible material suggesting income escapement, relying instead on information already available during original assessment. The court found that deduction claims u/s 54B and 54F were already considered in original assessment u/s 143(3). Reopening cannot be justified on grounds that original AO failed to inquire properly or adopted casual approach. Valid reassessment requires direct nexus with new information or tangible material, not reconsideration of existing facts. Petition allowed in favor of assessee. en-us Fri, 30 Aug 2024 00:00:00 +0530 Mon, 23 Sep 2024 09:10:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759032 Gujarat HC held that reassessment notice u/s 148 was invalid as it constituted mere change of opinion. Revenue authorities lacked new tangible material suggesting income escapement, relying instead on information already available during original assessment. The court found that deduction claims u/s 54B and 54F were already considered in original assessment u/s 143(3). Reopening cannot be justified on grounds that original AO failed to inquire properly or adopted casual approach. Valid reassessment requires direct nexus with new information or tangible material, not reconsideration of existing facts. Petition allowed in favor of assessee. Case-Laws Income Tax Fri, 30 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759032